How does BREXIT affect product & machine manufacturers?

The widely spoken and argued UK’s withdrawal from the EU is heading into its conclusion at the end of the year. Currently we are living in a Transition Period, where UK has withdrawn from the EU, and therefore cannot be part of decisions made by the EU bodies. However, the other rights and obligations of the Member States still apply for the UK, such as, the requirements for the CE-marking.

The Transition Period will terminate at the end of 2020, unless the UK and the EU will agree on a new trade deal sooner. Once the Transition Period ends, there will either be a new trade deal, or we might end up in a no-deal situation from January 1st 2021 onwards. Only time will tell.


  • January 31st 2020 – United Kingdom (UK) withdrew from the European Union (EU) and started the Transition Time for Brexit
  • March 2nd 2020 – Trade talks began between UK and EU
  • November 11th 2020 – UK did not reply to EU’s demand for clarification for the previous draft law that is undermining a previous resignation agreement.


  • December ?? 2020 New trade deal and end of transition time if agreement is reached
  • January 1st 2021 – New trade deal OR exit with no-trade deal


During the Transition Period the obligations of the CE-marking are unchanged, and thus nothing new is introduced with CE-marking for the UK market area. However, the EU will not accept CE markings from UK’s notified bodies starting from 1st of January 2021.

Whether the new trade deal is achieved or we’ll end up in “no-deal agreement”, there will be a new protocol to assess and mark the product safety for the UK and NI market area. The UK Conformity Assessed (UKCA) mark will be UK’s version of the CE-marking protocol. In similar fashion, there will be a UKNI-marking for Northern Ireland with their own requirements. These new markings will cover most of the goods that currently require the CE-marking.

To give businesses time to adjust, after the Transition Period most of the cases can still use CE-marking until 1st January 2022. However, with some of the new products, the UKCA- or UKNI- marking is required immediately after 1st of January 2021. Thus manufacturers are encouraged to prepare for new requirements as soon as possible.

In similar fashion to CE-marking, the UKCA-marking will also require Declaration of Conformity (DoC) with the product. However, the UKCA DoC must refer to UK’s legislation; the Statutory Instruments (SIs). There are currently in excess of 600 SIs for Brexit since 2018. In addition, the UK DoC will need references to UK designated standards, when these are available.

Are you, or your company, prepared for the new trade deal for the UK? Contact us for further information on how Etteplan could help you and your products with the UK requirements.

Etteplan Antti Karhukivi

Antti Karhukivi

Lead Safety Specialist
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